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(FILED: SUFFOLK COUNTY CLERK 0770572022 12:19 PM INDEX NO. 606238/2021
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 07/05/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
CONSTANCE MANSFIELD, DISCLOSURE DEMAND
Plaintiff, Index No. 606238/2021
-against-
EMILY A. DAMATO and ANTHONY S. DAMATO,
Defendants.
PLEASE TAKE NOTICE that, pursuant to Article 31 of the CPLR, you are hereby required to
produce for discovery, inspection, and photocopying at the offices of Pillinger Miller Tarallo,
LLP, 555 Taxter Road, 5th Floor, Elmsford, NY 10523, on August 1, 2022, at 2:00 in the
afternoon of that day, the following documents and things:
1. Fresh, duly executed, HIPAA-compliant authorizations from plaintiff permitting Pillinger
Miller Tarallo and/or GEICO to obtain plaintiff's medical records from her primary care
physician(s), including any diagnostic films, for the period five years prior to the subject
accident to the present date.
PLEASE TAKE FURTHER NOTICE that the within demand is a continuing demand. In the
event that any of the above items are obtained after service of this demand, they are to be
furnished to the undersigned pursuant to this demand.
PLEASE TAKE FURTHER NOTICE that, upon your failure to produce the aforesaid
documents, at the time and place required in this notice, defendants will oppose any attempts to
place this case on the trial calendar of this court and/or appropriate motions for relief will be
made to this court.
1 of 3(FILED: SUFFOLK COUNTY CLERK 0770572022 12:19 PM INDEX NO. 606238/2021
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 07/05/2022
PLEASE TAKE FURTHER NOTICE that, in lieu of producing the items demanded herein,
you may serve and submit to the undersigned true and conformed copies of the items demanded
herein at any time prior to the aforesaid date.
Dated: Elmsford, New Y ork
July 1, 2022
Y ours, etc.,
Kenneth A. Finder
PILLINGER MILLER TARALLO, LLP
KENNETH A. FINDER
Attorneys for Defendants
Emily A. Damato and Anthony S. Damato
555 Taxter Road, 5th Floor, Elmsford, NY 10523
Office No: (914) 703-6300
PMT File No. GIC-01948/KAF
TO:
WINKLER KURTZ, LLP
Attorney for Plaintiff
Constance Mansfield
1201 Route 112, Suite 200
Port Jefferson, NY 11776
Phone: (631) 928-8000
KAF/mh
2 of 3(FILED: SUFFOLK COUNTY CLERK 0770572022 12:19 PM INDEX NO. 606238/2021
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 07/05/2022
INDEX NO. 606238/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
Xx
CONSTANCE MANSFIELD,
PLAINTIFF,
-AGAINST-
EMILY A. DAMATO AND ANTHONY S. DAMATO,
DEFENDANTS.
DISCLOSURE DEMAND
PILLINGER MILLER TARALLO, LLP
Attorneys for Defendants
Emily A. Damato and Anthony S. Damato
555 Taxter Road, 5th Floor, Elmsford, NY 10523
(914) 703-6300
GIC-01948/KAF
CERTIFICATION PURSUANT TO 22 NY.C.R.R. § 130-1. Ja
Kenneth A. Finder hereby certifies that, pursuant to 22 N.Y.C.R.R. § 130-1.1a, the foregoing DISCLOSURE
DEMAND is/are neither frivolous nor frivolously presented.
Dated: Elmsford, New Y ork KennetivA. Finder
July 1, 2022 KENNETH A. FINDER
PLEASE TAKE NOTICE
that the within is a true copy of a entered in the office of the clerk of the within named Court on
that a of which the within is a true copy will be presented for settlement to the Hon. one of
the judges of the within named Court at , onat 9:30 am.
PALLINGER MILLER TARALLO, LLP
Attorneys for Defendants
Emily A. Damato and Anthony S. Damato
555 Taxter Road, 5th Floor, Elmsford, NY 10523
(914) 703-6300
PMT File No. GIC-01948/KAF
KAF/mh
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Preview
(FILED: SUFFOLK COUNTY CLERK 0770572022 12:19 PM INDEX NO. 606238/2021 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 07/05/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK CONSTANCE MANSFIELD, DISCLOSURE DEMAND Plaintiff, Index No. 606238/2021 -against- EMILY A. DAMATO and ANTHONY S. DAMATO, Defendants. PLEASE TAKE NOTICE that, pursuant to Article 31 of the CPLR, you are hereby required to produce for discovery, inspection, and photocopying at the offices of Pillinger Miller Tarallo, LLP, 555 Taxter Road, 5th Floor, Elmsford, NY 10523, on August 1, 2022, at 2:00 in the afternoon of that day, the following documents and things: 1. Fresh, duly executed, HIPAA-compliant authorizations from plaintiff permitting Pillinger Miller Tarallo and/or GEICO to obtain plaintiff's medical records from her primary care physician(s), including any diagnostic films, for the period five years prior to the subject accident to the present date. PLEASE TAKE FURTHER NOTICE that the within demand is a continuing demand. In the event that any of the above items are obtained after service of this demand, they are to be furnished to the undersigned pursuant to this demand. PLEASE TAKE FURTHER NOTICE that, upon your failure to produce the aforesaid documents, at the time and place required in this notice, defendants will oppose any attempts to place this case on the trial calendar of this court and/or appropriate motions for relief will be made to this court. 1 of 3(FILED: SUFFOLK COUNTY CLERK 0770572022 12:19 PM INDEX NO. 606238/2021 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 07/05/2022 PLEASE TAKE FURTHER NOTICE that, in lieu of producing the items demanded herein, you may serve and submit to the undersigned true and conformed copies of the items demanded herein at any time prior to the aforesaid date. Dated: Elmsford, New Y ork July 1, 2022 Y ours, etc., Kenneth A. Finder PILLINGER MILLER TARALLO, LLP KENNETH A. FINDER Attorneys for Defendants Emily A. Damato and Anthony S. Damato 555 Taxter Road, 5th Floor, Elmsford, NY 10523 Office No: (914) 703-6300 PMT File No. GIC-01948/KAF TO: WINKLER KURTZ, LLP Attorney for Plaintiff Constance Mansfield 1201 Route 112, Suite 200 Port Jefferson, NY 11776 Phone: (631) 928-8000 KAF/mh 2 of 3(FILED: SUFFOLK COUNTY CLERK 0770572022 12:19 PM INDEX NO. 606238/2021 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 07/05/2022 INDEX NO. 606238/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK Xx CONSTANCE MANSFIELD, PLAINTIFF, -AGAINST- EMILY A. DAMATO AND ANTHONY S. DAMATO, DEFENDANTS. DISCLOSURE DEMAND PILLINGER MILLER TARALLO, LLP Attorneys for Defendants Emily A. Damato and Anthony S. Damato 555 Taxter Road, 5th Floor, Elmsford, NY 10523 (914) 703-6300 GIC-01948/KAF CERTIFICATION PURSUANT TO 22 NY.C.R.R. § 130-1. Ja Kenneth A. Finder hereby certifies that, pursuant to 22 N.Y.C.R.R. § 130-1.1a, the foregoing DISCLOSURE DEMAND is/are neither frivolous nor frivolously presented. Dated: Elmsford, New Y ork KennetivA. Finder July 1, 2022 KENNETH A. FINDER PLEASE TAKE NOTICE that the within is a true copy of a entered in the office of the clerk of the within named Court on that a of which the within is a true copy will be presented for settlement to the Hon. one of the judges of the within named Court at , onat 9:30 am. PALLINGER MILLER TARALLO, LLP Attorneys for Defendants Emily A. Damato and Anthony S. Damato 555 Taxter Road, 5th Floor, Elmsford, NY 10523 (914) 703-6300 PMT File No. GIC-01948/KAF KAF/mh 3 of 3